Revision of the Ambient Air Quality Directive

ClientEarth argues that the European Commission's proposal for a recast Ambient Air Quality Directive lacks sufficient ambition and contains legal loopholes. The organization recommends aligning limit values with WHO Air Quality Guidelines by 2030, accelerating the timeline for 'Delivery Plans' to avoid widespread breaches in 2030, and introducing time-based financial sanctions for public authorities that fail to meet deadlines. It also advocates for maintaining and strengthening provisions for access to justice and health-related compensation for citizens.

• The proposed limit values for pollutants like PM2.5 and NO2 are not sufficiently protective, as they would allow concentrations twice as high as the health-based recommendations of the World Health Organization (WHO).
• The Proposal's reliance on average exposure reduction obligations after 2030 is viewed as ineffective because it allows pollution hotspots to be ignored or offset by cleaner zones, which negatively impacts social justice and equality.
• The proposed timeframe for 'Delivery Plans' (Article 19(4)) is too late, potentially requiring plans only by late 2028 or 2029, which ClientEarth argues will lead to significant breaches of limit values by the 2030 deadline.
• There is a critical loophole in the 'Remedial Plans' process (Article 19(1)) where failure to comply by 2030 only triggers a plan update every few years without a final backstop, creating a cycle that can continue indefinitely.
• ClientEarth recommends the implementation of a system of time-based financial sanctions for public authorities that miss deadlines to incentivize urgent remedial action.
• The inclusion of provisions for access to justice (Article 27) and compensation for health damage (Article 28) is considered an essential improvement to address inequalities across EU Member States.

APA

ClientEarth (2023). Revision of the Ambient Air Quality Directive. https://www.clientearth.org/media/hquf2neh/revision-of-the-ambient-air-quality-directives_key-recommendations-to-improve-the-commission-proposal.pdf

Chicago

ClientEarth. Revision of the Ambient Air Quality Directive. 2023. https://www.clientearth.org/media/hquf2neh/revision-of-the-ambient-air-quality-directives_key-recommendations-to-improve-the-commission-proposal.pdf.

Wikipedia

{{cite report |author=ClientEarth |title=Revision of the Ambient Air Quality Directive |date=January 2023 |url=https://www.clientearth.org/media/hquf2neh/revision-of-the-ambient-air-quality-directives_key-recommendations-to-improve-the-commission-proposal.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{clientearth2023revision, author = {{ClientEarth}}, title = {{Revision of the Ambient Air Quality Directive}}, institution = {ClientEarth}, year = {2023}, month = jan, url = {https://www.clientearth.org/media/hquf2neh/revision-of-the-ambient-air-quality-directives_key-recommendations-to-improve-the-commission-proposal.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }